Frequently Asked Questions for NSF Funding

The NSF proposal and award guide states –

- Any substantial collaboration (foreign or domestic) with individuals not included in the budget should be described in the Facilities, Equipment and Other Resources section of the proposal (see Chapter II.C.2.i) and documented in a letter of collaboration from each collaborator. Such letters should be provided in the supplementary documentation section of the FastLane Proposal Preparation Module and follow the format instructions specified in Chapter II.C.2.j.¹

- Collaborative activities (foreign or domestic) that are identified in the budget should follow the instructions in Chapter II.D.3. Note: In this context, a collaborator is likely a subawardee and not a collaborator, as discussed above.

- Collaborations and Other Affiliations (COA) information. NSF requests information in spreadsheet form, where the PIs include lists of co-authors and collaborators. NSF uses this information to avoid conflicts of interest in proposal review. From the NSF proposal instructions, related to Table 4 -COA template Table 4: List names as last name, first name, middle initial, and provide organizational affiliations, if known, for the following: Co-authors on any book, article, report, abstract or paper with collaboration in the last 48 months (publication date may be later); and Collaborators on projects, such as funded grants, graduate research or others in the last 48 months.

- While collaborations not directly contributing to the project may not need to be listed in the proposal as "collaborator", the activity may be considered "in-kind support" if it includes a time commitment, for example, if a PI hosts a visiting researcher funded by an outside entity. See the in-kind support guidance and the FAQs below.

1. How do reporting requirements vary between collaborations from different countries?
   
   In addition to the information provided above, report "International Activities" on the proposal cover sheet. An International Activity is defined as research, training, and/or education carried out in cooperation with international counterparts either overseas or in the US using virtual technologies. Proposers also should enter the country/countries with which project participants will engage and/or travel to attend international conferences. If the specific location of the international conference is not known at the time of the proposal submission, proposers should enter "Worldwide." (See Chapter II.C.2.j).
   
   
2. What if I get an invitation to be a visiting (compensated) research collaborator at a Chinese university?
   
   Before you accept the invitation, you should talk with your Division Chair or supervisor to decide whether it would be acceptable. If you proceed with the engagement, several disclosures may be required to both Caltech and NSF:
   
   a. Disclose your appointment/position, if any, as a Commitment to Caltech (Caltech Disclosure of Financial Interests and Commitments (Caltech Disclosure)) and in your NSF Biosketch.
   
   b. Any compensation you receive through this relationship, e.g., travel funds or consulting fees must be disclosed to Caltech as a Financial Interest (Caltech Disclosure). If there are any personal payments to you support research, include them in the NSF Current & Pending Support.
   
   c. Any research funds you receive from the Chinese university must be reported as awards under Current & Pending Support.
   
   d. Any in-kind resources such as facilities, equipment, personnel, or other resources must be disclosed as NSF "In-Kind Support." (Sponsor Disclosure in proposal or RPPR) and in the Caltech Disclosure System.
   
   e. There may be additional Export Compliance concerns, IP concerns, and possible foreign engagement concerns. Please contact the Office of Research Compliance (ORC) for further guidance.
   
   
3. What issues are particular to the sort of global science collaborations many of us belong to?
   
   Issues:
   a. Conflict of Commitment (Caltech Disclosure)
   
   b. Financial Interest (Caltech Disclosure)
   
   c. Current & Pending Support & Biosketch (Sponsor Disclosure)
   
   d. Export Control issues, IP issues, possible foreign engagement issues
   
   
4. Where can we go to for authoritative guidance regarding a current or planned foreign collaboration?
   
   Contact the Office of Sponsored Research (OSR) regarding collaboration agreements. OSR will coordinate with other offices at Caltech, as necessary.
   
   
5. I have been and will continue to be a co-author on publications that involve many people, including those that I do not interact with. Do I need to report the collaborator(s) of my collaborator(s)?
   
   Reporting of collaborators on NSF proposals and awards is limited to 1) those that will contribute directly to the proposed project or 2) those that must be reported on the COA spreadsheet for purposes of identifying potential conflicts on proposal reviews. Consult the May 2018 NSF FAQ regarding the new COA spreadsheet.
   
   
6. What is the time frame for reporting a foreign collaboration? In the case of previous foreign collaborations that are not going on anymore, but which generated research results that are being included in current manuscripts, is that reportable or not?
   
   NSF requires reporting of foreign or domestic collaborations that contribute to a specific NSF project and requires a letter of support at the time of application. Researchers need not list those collaborators in the application that will not contribute to the NSF project, however any anticipated financial or in-kind support from a collaborator toward any of your research must be reported as Current & Pending Support. The collaborator may need to be reported on the COA spreadsheet. See NSF instructions or call ORS for more details.
   
   If the collaboration arose during the period of performance, include the collaborator in the next annual report. Contact OSR for instructions or questions.
   
   If a collaborator should have been disclosed but was not, Caltech is required to disclose the collaborator within 30 days of discovering the error. This does not apply to awards that are closed. Contact the Office of General Counsel for assistance in reporting items that you believe should have been reported earlier.
   
   
7. Does the reporting need to happen mostly at proposal submission time or is there a requirement that each new collaboration be reported when initiated during the life of a given NSF award?
   
   The primary disclosure of International Activities and collaborations occurs at the proposal stage or during the proposal update phase just before NSF makes an award. PIs are also required to update information about International Activities and Current & Pending Support throughout the life of the award. See the NSF post-award reporting instructions for more details.
   
   In addition, NSF award terms require that Caltech report any current awards or in-kind contributions that were not reported timely, within 30 days of discovering the error. Contact the Office of General Counsel for assistance in reporting items that you believe should have been reported earlier.
   
   
8. I have dozens of colleagues in foreign countries and more colleagues who are foreign nationals living in the US. How do I decide who to list in the Disclosure System? Can you provide any guidance as to what activities, if any, are defined as "collaboration" if there is no compensation or other support involved?
   
   These questions have been addressed in the NSF collaboration instructions above. However, as a rule of thumb regarding disclosure of collaborations, look toward publication. If you expect a foreign or domestic collaboration to result in a publication where you might acknowledge or confer authorship to your collaborator, it is likely a relationship that rises to the level of a collaborator and should be reported to the NSF.
   
   
9. A more likely scenario for collaboration: I have a former postdoc who went back to China. We continue to work together on projects unrelated to my sponsored projects here. What are the requirements for reporting to Caltech and NSF?
   
   If you have an appointment with the collaborator's institution or spend more than 13 days per quarter collaborating on research outside of Caltech, you should report that appointment or those activities exceeding 13 days to Caltech as a commitment. If you are paid or receive any type of compensation or equity >$4,999 for this collaboration, you should report this financial interest to Caltech.
   
   The NSF reporting requirement for collaborators is to name those directly contributing to the project in Facilities, Equipment and Other Resources. Because the collaborator is not directly contributing to the NSF-funded project, the person need not be reported to NSF.
   
   
10. Regarding foreign collaborations: my former students (now on the faculty in China) gave me co-authorship credit for the ideas I contributed 10 years ago while they were in my lab. Is this a foreign collaboration?
    
    There are a couple of options in this case. Option 1: Agree to be listed as a co-author based on ideas you've offered in the past, and if the NSF grant that supported the project 10 years ago is still active (unlikely), list the collaboration in your next annual report. Do not list any award as the source of support for a publication that did not directly relate to or support the publication. Option 2: You could decline co-authorship on the paper if your contribution does not rise to the level of true authorship on the paper, which sounds more likely in this case. The authors should include your contributions in the acknowledgments.
    
    
    ^{_1.From the proposal instruction in the PAPPG - (iv) Unfunded Collaborations}

The NSF proposal and award guide states –

NSF Current and Pending support includes information on all current and pending support for ongoing projects and proposals. The proposed project and all other projects or activities requiring a portion of the PI/senior personnel's time must be included, even if they receive no salary support from the project(s). This also includes consulting activities that involve performing research for other entities. See the NSF page for more details.

1. If you receive personal compensation for your role as a journal editor, do you need to report this as Personal Other Support?
   
   Unless you plan to use the compensation to support research, it does not need to be disclosed in Current & Pending Support. If you are being appointed as an editor, you must include the position on your Biosketch. In any case, you must disclose your time commitment and the income in your Caltech Disclosure.
   
   
2. Do reported activities affect the chance of the proposal getting funded?
   
   Yes. NSF states that it considers the information submitted in the current and pending support section to assess the capacity of the individual to carry out the research as proposed, as well as to help assess any potential overlap/duplication with the project being proposed.

The NSF proposal and award guide states –

Gifts given without conditions or an expectation of anything in return need not be reported. However, if the item or service is given with the expectation of an associated time commitment, it does not meet NSF's definition of a "gift" and should be reported as an in-kind contribution.

NSF's definition of "gift" includes "any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, license, special access, equipment time, samples, research data, or other item having monetary value." The definition of "gift" also includes "services as well as gifts of training, transportation, local travel, lodging, meals, research hours, whether provided in-kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has occurred."

1. Are unrestricted gifts reportable?
   
   True unrestricted gifts are not included in Current & Pending Support. However, Caltech has determined that funds designated for a specific research area/activity/lab do not meet the NSF definition of a "gift" and must be included as Other Support.
   
   
2. I did not previously disclose gift funds that now appear to require disclosure. Should I submit an updated Current & Pending Support report? If so, how should this be done?
   
   If you have an existing NSF grant and a gift was provided after your last annual report (RPPR), you can disclose the gift in an updated Current & Pending Support report in your next RPPR. If you are submitting a new proposal, you can disclose the gift in Current & Pending Support.
   
   If you believe you need to disclose Current & Pending Support that was previously missed or not reported timely, please contact the Office of General Counsel. If you and OGC determine that the gift should be reported, you will work with OSR to submit the retroactive disclosure to NSF.

The NSF proposal and award guide states that consulting activities that include performing research for an outside entity must be reported as Current & Pending Support.

The NSF defines "research" as a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. Research is classified as either basic or applied according to the objectives of the sponsoring agency. https://www.nsf.gov/statistics/fedfunds/glossary/def.htm#research

1. I am confused by the NSF reporting requirement to report consulting agreements. What does it mean that a consulting agreement involves (or doesn't involve) a research activity? The issue is: the consultant can be "officially" working on R&D for the company, but as we know, commercial R&D is often very different from our research here, e.g., it develops an algorithm using standard public research results that can be used commercially, so it's not publishable research, even though officially it contributes to company R&D.
   
   If the consulting contract states that it's for commercial Research and Development, it should be disclosed as a research activity on your Current & Pending Support, whether or not the work is publishable. For cases that are not as clear-cut, review the NSF definition of research to help you decide if a consulting relationship must be reported. For example, consulting that includes acting as an expert witness or being on a science advisory board typically does not involve performing research. On the other hand, helping a company with their SBIR/STTR proposal/award, designing/conducting experiments, or providing training in research techniques as part of your outside activities are likely examples of performing research.
   
   We recognize that this is new, and therefore, not a straightforward area. When the matter is unclear, it protects both the researcher and Caltech for the researcher to disclose.
   

The NSF proposal and award guide states that in-kind support includes all resources provided in support of all of the investigator's researcher endeavors, such as office/laboratory space, equipment, supplies, employees, students, and visitors. Note that "conditional" gifts may also be considered in-kind support.

If an in-kind contribution is not intended for use on the project/proposal being proposed to NSF but has an associated time commitment, the information must be included as part of the Current and Pending Support section of the proposal.

If an in-kind contribution is intended for use on the project/proposal being proposed to NSF and either has an associated time commitment or not, the information must be included as part of the Facilities, Equipment, and Other Resources section of the proposal and need not be replicated in the individual's Current &Pending Support submission.

If an in-kind contribution is not used on the project/proposal being proposed to NSF and has no associated time commitment, it need not be reported.

1. How do we deal with postdocs supported by funding from their country of origin (i.e., EMBO, DFG, Wellcome, Marie Curie)?
   
   Visiting scholars, including visiting postdocs and visiting graduate students, do not need to be reported so long as the faculty member's collaboration/mentorship occurs at Caltech as part of the faculty member's institutional activities.
   
   
2. Is a visit by a non-degree graduate student researcher funded by China Scholarship Council reportable under any circumstances?
   
   A visit by non-degree graduate student researchers is not permitted unless they are participating in a Caltech-approved program (SURF/VURP). In this case, NSF does not require that this be reported as "in-kind" support since the mentorship would be considered part of the PI's Caltech responsibilities. See FAQ 5.
   
   
3. What if I serve on a Ph.D. or master's thesis committee for a student at another university (foreign or domestic); is the student or any compensation I receive considered to be in-kind support?
   
   If that student is not part of your group or contributing work to your research at Caltech, then this would not be considered "in-kind" support on your federally funded awards, nor would be any compensation received. If you are receiving more than $5,000 in compensation over a 12-month period, this must be reported in the Caltech Disclosure system. However, if you receive an appointment at the other university, this activity should be disclosed on your NSF Biosketch.
   
   
4. Caltech often accepts visiting Chinese graduate students who are paid through Chinese fellowships. What needs to be disclosed in these cases? What if the visitor helps on a project related to an NSF-funded project's objectives, but they are not paid from the project?
   
   A visit by a non-degree graduate student researcher is not permitted unless they are participating in a Caltech-approved program (SURF/VURP). If the visiting student is working on an NSF-funded project, the visitor should be reported as in-kind support in the Facilities, Equipment, and Other Resources section of the proposal.
   
   
5. Do we report our past foreign visitors, for example, from China one year ago? If so, where do we report it?
   
   If your NSF award was active when the visitor was here, you might need to report retrospectively. Contact the Office of General Counsel to discuss details.
   

The NSF proposal and award guide states that investigators must disclose all positions, domestic and foreign, including

• titled academic, professional, or institutional affiliations
• full-time, part-time, or voluntary (including adjunct, visiting, honorary positions)
• whether or not remuneration is received

Investigators are urged to use ORCiD Open Researcher and Contributor ID. More information may be found at: https://libguides.caltech.edu/orcid.

Regarding NSF Biosketch requirements to list ALL appointments: What about serving on a board of a non-profit organization or a for-profit company? What about serving on a scientific advisory board of a foundation? Which of these are required to be included?

You must disclose all titled academic, professional, or positions, domestic and foreign, including titled academic, professional, or institutional, regardless of whether full-time, part-time, voluntary, adjunct, visiting, honorary, or whether or not remuneration is received.

These appointments need to be disclosed in your Biosketch. If appointments include any support (financial or in-kind) for research activity, you also need to report the appointment and support in Current & Pending Support. The appointment also needs to be disclosed to Caltech (Caltech Disclosure).